Sanctions Screening & Due Diligence
Penalties & Consequences
GitLab Policies
Data Privacy & Protection
Government Officials
100

This is the tool that GitLab uses to screen vendors, prospects, and customers for sanctions.

What is Risk Rate?

100

This consequence specifically affects GitLab's ability to do business with the government.

What is debarment?

100

The GitLab document that establishes standards of business conduct and must be acknowledged annually by all team members.

What is the Code of Business Conduct and Ethics?

100

This 2016 EU regulation governs data protection and privacy for EU citizens and has extraterritorial reach.

What is the GDPR?

100

This U.S. law governs interactions with government officials and prohibits bribery.

What is the Foreign Corrupt Practices Act (FCPA)?

200

At GitLab, sanctions screening fails without this information, when the prospect or customer is located in Canada.

What is province? Also acceptable: Account Name or Account Address

200

Knowingly ignoring red flags can result in this internal GitLab action.

What is disciplinary action?

200

This policy protects team members who report violations in good faith.

What is the Anti-Retaliation Policy (or Whistleblower Policy)?

200

This is information that can be used to identify an individual.

What is personal data?

200

This is the maximum value per person per event for gifts or entertainment to foreign government officials without pre-approval.

What is $80?

300

Unusual payment requests, vague business purposes, or evasive answers about end users are examples of these warning signs that require escalation to Ethics & Compliance.

What are red flags?

300

Companies that violate trade regulations may lose this privilege, preventing them from exporting products or technology.

What are export privileges (or export licenses)?

300

Team members must contact Ethics & Compliance immediately upon receiving requests related to this type of unauthorized foreign boycott.

What is any boycott-related request?

300

Under GDPR, companies must report data breaches to supervisory authorities within this many hours.

What is 72 hours?

300

Contact with foreign officials may require documentation to avoid even the appearance of this prohibited practice.

What is bribery?

400

When Risk Rate flags a potential match to a sanctioned party, the system puts the account into this status until Legal has a chance to review it. 

What is "export hold" or "requires review?"

400

Under U.S. export control laws, criminal penalties for violations can include fines up to this amount per violation and up to 20 years imprisonment.

What is $1 million?

400

and Entertainment Policy mentions two major anti-corruption laws: the U.S. Foreign Corrupt Practices Act and this UK law.

What is the UK Bribery Act?

400

GDPR requires that personal data be collected for specified, explicit purposes and not processed in a manner incompatible with those purposes, known as this principle.


What is purpose limitation?

400

These small payments to speed up routine government actions are prohibited under the UK Bribery Act and GitLab's Gifts and Entertainment Policy.

What are facilitation payments?

500

Accounts located in this South American country are treated as high-risk and require further review by GitLab's Trade Compliance Counsel.

What is Venezuela?

500

Under GDPR, companies can face fines up to this percentage of annual global revenue for serious data protection violations.

What is 4%?

500

According to GitLab's Gifts and Entertainment Policy, this is the maximum value per person per event for gifts or entertainment to U.S. government officials.

What is $20?

500

Under GDPR, individuals have this right to request deletion of their personal data under certain circumstances.

What is the right to erasure (or right to be forgotten)?

500

Providing anything of value to a foreign official with the intent to influence their official actions violates anti-corruption laws and constitutes this illegal act.

What is bribery?